The Scottish Government published its analysis of responses to the Part II consultation on the New Build Heat Standard in June 2023. The consultation ran from 28 July to 20 October 2022 and received 112 responses, from 21 individuals and 91 organisations1. It contained six closed and eight open questions, and 89% of respondents granted permission for publication of their responses1.
The standard would prohibit direct emissions heating (DEH) systems in new buildings and some conversions warranted from April 2024, using powers under the Buildings (Scotland) Act 20031. The Building (Scotland) Amendment Regulations 2022 defined a DEH system as a system by which the building is heated or is cooled, or by which hot water is made available1. Three fifths (62%) of those answering Q1 agreed with the proposed approach to regulate DEH systems in new buildings, 30% disagreed and 7% were unsure1. Agreement was higher among organisations than individuals, at 66% compared to 52%1. All local authorities (100%) agreed, as did 80% of manufacturers and suppliers in the energy sector, while views among energy sector trade bodies were more mixed: half (50%) agreed, 25% disagreed and 25% were unsure1. Among property developers and builders, 63% disagreed with the proposed approach, with 38% agreeing1.
| Respondent group | Agreed with proposed approach |
|---|---|
| All answering Q1 | 62% |
| Organisations | 66% |
| Individuals | 52% |
| Local authorities | 100% |
| Energy manufacturers and suppliers | 80% |
| Energy trade bodies | 50% |
| Property developers and builders | 38% |
The analysis records that many who agreed raised potential unintended consequences. The most prevalent concern was the perception that Scotland's current electrical grid capacity and infrastructure is insufficient, with several highlighting that the proposals could be challenging to implement in rural or island areas which may be off-grid or where capacity may be lower1. The second most prevalent theme was challenges with the supply, installation and maintenance of zero-direct emissions heating (ZDEH) systems, due to skills and material shortages1. Other possible consequences listed included the delay or termination of planned developments of new homes, the possibility that more expensive heating systems could exacerbate fuel poverty, consumer unease over ZDEH technology, and an uneven impact on rural areas with more off-grid locations1.
"Their views will assist the Scottish Government in finalising the NBHS regulations to put to Parliament in 2023."
The document states the Scottish Government intends to prepare legislation in Spring 2023 for the NBHS coming into force in April 20241. It describes the standard as the culmination of years of research starting with "A Low Carbon Building Standards Strategy For Scotland" published in 2007 and updated in 20131. During the consultation process the Scottish Government held three engagement events with stakeholders: a Consumer and Equality Workshop, an Island Communities Workshop, and a Non-Domestic Building Workshop1.
Why it matters for households
The standard applies to new buildings rather than existing homes, so it does not by itself change the heating system in a home that is already occupied. Its practical effect for households is on what heating a newly built home in Scotland will contain, and therefore on the running costs and infrastructure a buyer or tenant inherits. The consultation analysis shows the main reservations were about whether the electricity grid can carry the additional load, particularly in rural and island areas, and whether there are enough skilled installers and materials to fit and maintain the systems1. Respondents also raised the prospect that more expensive heating systems could worsen fuel poverty, and that poorly built or poorly insulated homes may need substantial work before a zero-direct emissions system operates effectively1. How Scottish homes are heated, and the wider policy landscape, are set out in How Scottish Homes Are Heated and the regulation-policy hub.
What happens next
The analysis states the Scottish Government intends to prepare legislation in Spring 2023 for the NBHS coming into force in April 2024, and that respondents' views will assist it in finalising the NBHS regulations to put to Parliament in 20231. No further timetable beyond those points is given in the document.